III.  ACCOUNTABILITY AND THE RIGHTS OF VICTIMS The Trial Chamber of the International Criminal Tribunal for the former Yugoslavia held that “the drafters of the Convention did not deem the existence of an organization or a system serving a genocidal objective as a legal ingredient of the crime. In so doing, they did not discount the possibility of a lone individual seeking to destroy a group as such.” Nevertheless, the Trial Chamber noted that “it will be very difficult in practice to provide proof of the genocidal intent of an individual if the crimes committed are not widespread and if the crime charged is not backed by an organization or a system.”115 Even in the case of genocide, this organizational affiliation does not relate only to State actors, but also to non-State actors engaged in an armed conflict. Crimes against humanity may equally be committed by individuals affiliated with non-State armed groups. Regarding war crimes, insofar as non-State entities have important obligations in international humanitarian law, their violations fall within the same legal framework applicable to States. For example, the Security Council, in its resolution 1214 (1998), recalled to all parties in the context of the Afghan internal armed conflict that “persons who commit or order the commission of breaches of the [Geneva] Conventions are individually responsible in respect of such breaches”, which demonstrates that modern international humanitarian law applies the same standards to State and to non-State actors. (c)  Command responsibility While the general principle for imposing individual criminal responsibility for violations of international humanitarian law requires a direct participation, international criminal law recognizes the importance of leaders and commanders in ensuring that individuals under their command do not engage in any type of criminal behaviour leading to gross violations of international human rights law or international humanitarian law. In this respect, article 86.2 of Protocol I indicates that a breach of the obligations under the Conventions by a subordinate does not absolve the superiors   Prosecutor v. Goran Jelisic´, case No. IT-95-10-T, Judgement of 14 December 1999, paras. 100–101. 115 79